U.	S.	Department	of	Transportation																					Regulatory	Docket	No.	FAA-2015-0029-0001

Docket	Management	System

1200	New	Jersey	Ave.,	SE

Washington,	DC	20590

Re:	Exemption	Request	Section	333	of	the	FAA	Reform	Act	and	Part	11	of	the	Federal	Aviation

Regulations	from	14	C.F.R.	45.23(b);	14	C.F.R.	Part	21;	14	C.F.R.	Part	61.113(a)	&	(b);	91.7	(a);

91.9	(b)	(2);	91.103	(b);	91.109;	91.119;	91.121;	91.151	(a);	91.203	(a)	&	(b);	91.405	(a);	91.407	(a)

(1);	91.409	(a)	(2);	91.417	(a)	&	(b).

Dear	Sir	or	Madam,

					 Pursuant	to	Section	333	of	the	FAA	Modernization	and	Reform	Act	of	2012	(the	Reform

Act)	and	14	C.F.R.	Part	11,	G5 Drones,	owned	and	operated	by a	Commercially	Rated	Pilot and

operators	of	Small	Unmanned	Aircraft	SYSTEMS	(“UAS”)	equipped	to	conduct	aerial

photography	and	cinematography	for	commercial	and	residential	real	estate	and	closed-set

special	events,	hereby	applies	for	an	exemption	from	the	listed	Federal	Aviation	Regulations

(“FARs”)	to	allow	commercial	operation	of	its	UAS,	so	long	as	such	operations	are	conducted

within	and	under	the	conditions	outlined	herein	or	as	may	be	established	by	the	FAA	as

requires	by	Section	333.

					 As	described	more	fully	below,	the	request	exemption	would	permit	the	operation	of

small,	unmanned, and	redundant	UAS	under	controlled	conditions	in	airspace	that	is	1)	limited

2)	predetermined	3)	controlled	as	to	access	and	4)	would	provide	safe	operations	and

affordability	to	the	existing	real	estate	and	closed-set	special	event	industries	currently	using

conventional	aircraft.	Approval	of	this	exemption	would	thereby	enhance	safety,	promote

industry	growth	and	fair	competition	through	affordability	of	aerial	photography	and

cinematography	and	fulfill	the	Secretary	of	Transportation’s	(the	FAA	Administrator’s)

responsibilities	to	“...	establish	requirements	for	the	safe	operation	of	such	aircraft	systems	in

the	national	airspace	system.”	Section	333	of	the	Reform	Act.

The	name	and	address	of	the	applicant	is:

																			 G5	 Drones

Attn:										Monte	O.	Griffin

Ph:												 806-672-6632

Email:						 mogriffin@earthlink.net

Address:		 31216	CR	437		Sorrento	Fl.	32776

Regulations	from	which	the	exemption	is	requested:

14	C.F.R.	Part	21																															

14	C.F.R.	45.23	(b)																										

14	C.F.R.	61.113	(a)	&	(b)

14	C.F.R.	91.7	(a)

14	C.F.R.	91.9	(b)	(2)

14	C.F.R.	91.103

14	C.F.R.	91.109

14	C.F.R.	91.119

14	C.F.R.	91.121

14	C.F.R.	91.151	(a)

14	C.F.R.	91.203	(a)	&	(b)

14	C.F.R.	91.405	(a)

14	C.F.R.	407	(a)	(1)

14	C.F.R.	409	(a)	(2)

14	C.F.R.	417	(a)	&	(b)
					This	exemption	application	is	expressly	submitted	to	fulfill	Congress’	goal	in	passing

Section	333(a)	through	(c)	of	the	Reform	Act.	This	law	directs	the	Secretary	of	Transportation

to	consider	whether	certain	unmanned	aircraft	systems	may	operate	safely	in	the	national

airspace	system	(NAS)	before	completion	of	the	rule	making	required	under	Section	332	of	the

Reform	Act.	In	making	this	determination,	the	Secretary	is	required	to	determine	which	types

of	UASs	do	not	create	a	hazard	to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national

security	in	light	of	the	following:

•	The	UAS’s	size,	weight,	speed	and	operational	capability;

•	Operation	of	the	UAS	in	close proximity	to	airports	and	populated	areas;	and

•	Operation	of	the	UAS	within	visual	line	of	sight	of	the	operator.

Reform	Act	§	333	(a).	Lastly,	id. the	Secretary	determines	that	such	vehicles	“may	operate	safely

in	the	national	airspace	system,	the	Secretary	shall	establish	requirements	for	the	safe	operation

of	such	aircraft	in	the	national	airspace	system.”	Id.	§333(c).

					The	Federal	Aviation	Act	expressly	grants	the	FAA	the	authority	to	issue	exemptions.

This	statutory	authority	by	its	terms	includes	exempting	civil	aircraft,	as	the	term	is	defined

under	§40101	of	the	Act,	that	includes	UAS,	from	the	requirement	that	all	civil	aircraft	must

have	a	current	airworthiness	certificate.

					The	Administrator	may	grant	an	exemption	from	a	requirement	of a	regulation

prescribed	under	subsection	(a)	or	(b)	of	this	section	or	any	sections	44702	- 44716	of	this	title

if	the	Administrator	finds	the	exemption	in	the	public	interest.	49	U.S.C.	§44701(f)	See	also

49	USC	§44711(a);	49	USC	§44704;	14	CFR	§91.203	(a)	(1).

G5 Drones	proposes	to	use	one UAS;	1)	DJI	PHANTOM	2	Vision	+.	This	aircraft

has	four	rotors	and	four	motors	in	a	quadcopter	configuration	(X4).	This	UAS	weigh	less

than	55	lbs.	including	payload.	They	operate,	under	normal	conditions	at	a	speed	of	no	more

than	30	knots	and	have	the	capability	to	hover,	and	move	in	the	vertical	and	horizontal	plane

simultaneously.	This UAS is equipped	with	GPS	and	auto-return	function	to	the

predetermined	safe	landing	area	as	well	as	allowing	reading	of	magnetic	interference	that	can

cause	loss	off	GPS	signal.	The	UAS	will	operate	only	in	line	of	sight	and	will	operate	only

within	a	sterile	closed-set	area	of	a	residential	or	commercial	listing	or	a	closed-set	special

event.	Such	operations	will	insure	that	the	UAS	will	“not	create	a	hazard	to	users	of	the

national	airspace	system	or	the	public.”	(Reform	Act	Section	333	(b)).

					Given	the	small	size	of	the	UAS	involved	and	the	restricted	sterile	environment	within

which	they	will	operate,	the	applicant	falls	squarely	within	that	zone	of	safety	(an	equivalent

level	of	safety)	in	which	Congress	envisioned	that	the	FAA	must,	by	exemption,	allow

commercial	operations	of	UASs	to	commence	immediately.	Also	due	to	the	size	of	the	UASs

and	the	restricted	areas	in	which	the	relevant	UAS	will	operate,	approval	of	the	application

presents	no	national	security	issue.	Given	the	clear	direction	in	Section	333	of	the	Reform	Act,

the	authority	contained	in	the	Federal	Aviation	Act,	as	amended;	the	strong	equivalent	level	of

safety	surrounding	the	proposed	operations,	and	the	significant	public	benefit,	including

enhanced	safety,	reduction	in	environmental	impacts,	including	reduced	emissions	associated

with	allowing	UASs	for	movie	and	television	operations,	the	grant	of	the	requested	exemptions

is	in	the	public	interest.	Accordingly,	the	applicant	respectfully	requests	that	the	FAA	grant	the

requested	exemption	without	delay.
AIRCRAFT	AND	EQUIVALENT	LEVEL	OF	SAFETY

G5 Drones	proposes	that	the	exemption	requested	herein	apply	to	civil	aircraft	that

have	the	characteristics	and	that	operate	with	the	limitations	listed	herein.	These	limitations

provide	for	at	least	an	equivalent	or	even	higher	level	of	safety	to	operations	under	the	current

regulatory	structure	because	the	proposed	operations	represent	a	safety	enhancement	to	the

already	safe	aerial	photography	and	cinematography	filming	operations	conducted	with

conventional	aircraft.

					These	limitations	and	conditions	to	which	G5 Drones	agrees	to	be	bound	when

conducting	commercial	operations	under	an	FAA	issued	exemption	include:

1.	The	UAS	will	weigh	less	than	55	lbs.

2.	Flights	will	be	operated	within	line	of	sight	of	a	pilot	and/or	observer.

3.	Maximum	total	flight	time	for	each	operational	flight	will	be	20	minutes	or	less.

Flights	will	be	terminated	at	25%	battery	power	reserve	should	that	occur	prior	to

the	30	minute	limit.

4.	Flights	will	be	operated	at	an	altitude	of	no	more	than	400	feet	AGL	or,	not	more

than 200	feet	above	an	elevated	platform	for	which	filming	is	planned.

5.	Minimum	crew	for	each	operation	will	consist	of	the	UAS	Pilot,	the

Visual	Observer,	and	or Camera	Operator.

6. UAS	Pilot	will	be	FAA	licensed	airman	with	at	least	a	Private Pilot’s	certificate

and	a	third class	medical.

7.	The	UAS	will	only	operate	within	a	confined	sterile	closed-set	area	with	a	set	safety

perimeter,	the	boundaries	of	which	will	be	determined	by	production	personnel	and

the	UAS	PIC	based	on	the	site-specific	filming	activities	and	speed	of	the	UAS

required	for	the	operation,	and	coordinated	with	the	jurisdictional	FAA	FSDO	and

local	government	officials	as	applicable.

8.	A	briefing	will	be	conducted	in	regards	to	the	planned	UAS	operations	prior	to

each	day’s	production	activities.	It	will	be	mandatory	that	all	personnel	who	will	be

performing	duties	within	the	boundaries	of	the	safety	perimeter	be	present	for	this

briefing.

9.	The	UAS	Pilot	and/or	Aerial	Coordinator	will	ensure	this	safety	perimeter	that	only

consenting	production	personnel	will	be	allowed	within	100	feet	of	the	UAS

operation	by	not	permitting	anyone	who	had	not	been	briefed	or	whom	is	not

involved	in	production	to	be	in	the	closed-set	area.

10.	Observer	and	PIC	will	at	all	times	be	able	to	communicate	by	voice	and/or	two	way

radio	communication	system.

11.	Written	and/or	oral	permission	from	the	relevant	property	holders	will	be	obtained.

12.	If	applicable,	all	required	permissions	and	permits	will	be	obtained	from	territorial,

state,	county	or city	jurisdictions,	including	local	law	enforcements,	fire,	or	other

appropriate	governmental	agencies.

13.	If	the	UAS	loses	communications	or	loses	its	GPS	signal,	the	UAS	will	have	the

capability	to	return	to	a	pre-determined	location	within	the	Security	Perimeter	and

land	safely.

14.	The	UAS	will	have	the	capability	to	abort	flight	in	case	of	unpredicted	obstacles	or

emergencies.
14	C.F.R.	Part	21,	Subpart	H:	Airworthiness	Certificates	14	C.F.R.	§91.203	(a)	(1)

					Subpart	H,	entitled	Airworthiness	Certificates,	establishes	the	procedural	requirements

for	the	issuance	of	airworthiness	certificates	as	required	by	FAR	§91.203	(a)	(1).	Given	the	size

and	limited	operating	area	associated	with	the	aircraft	to	be	utilized	by	the	Applicant,	an

exemption	from	Part	21	Subpart	H	meets	the	requirements	of	an	equivalent	level	of	safety

under	Part	11	and	Section	333	of	the	Reform	Act.	The	Federal	Aviation	Act	(49	U.S.C.§44701

(f))	and	Section	333	of	the	Reform	Act	both	authorize	the	FAA	to	exempt	aircraft	from	the

requirement	for	an	airworthiness	certificate,	upon	consideration	of	the	size,	weight,	speed,

operational	capability,	and	proximity	to	airports	and	populated	areas	of	the	particular	UAS.	In	all

cases,	an	analysis	of	these	criteria	demonstrates	that	the	UAS	operated	without	an

airworthiness	certificate,	in	the	restricted	environment	and	under	the	conditions	proposed	will

be	at	least	as	safe,	or	safer,	than	a	conventional	aircraft	(fixed	wing	or	rotorcraft)	operating	with

an	airworthiness	certificate	without	the	restrictions	and	conditions	proposed.

14	C.F.R.	§	45.23	(b).	Marking	of	the	Aircraft

The	regulation	requires:

When	marks	include	only	the	Roman	capital	letter	"N"	and	the	registration

number	is	displayed	on	limited,	restricted	or	light-sport	category	aircraft	or

experimental	or	provisionally	certificated	aircraft,	the	operator	must	also	display

on	that	aircraft	near	each	entrance	to	the	cabin,	cockpit,	or	pilot	station,	in

letters	not	less	than	2	inches	nor	more	than	6	inches	high,	the	words	"limited,"

"restricted,"	"light-sport,"	"experimental,"	or	"provisional,"	as	applicable.

Even	though	the	sUAS	will	have	no	airworthiness	certificate,	an	exemption	may	be

needed	as	the	sUAS	will	have	no	entrance	to	the	cabin,	cockpit	or	pilot	station	on	which	the

word	“experimental”	can	be	placed.	Given	the	size	of	the	UAS,	two	inch	lettering	will	be

impossible.	The	word	“Experimental”	will	be	placed	on	the	fuselage	in	compliance	with	§45.29

(f).

The	equivalent	level	of	safety	will	be	provided	by	having	the	UAS	marked	on	its	fuselage

as	required	by	§45.92	(f)	where	the	pilot,	observer	and	others	working	with	the	UAS	will	see

the	identification	of	the	UAS	as	“Experimental”.	The	FAA	has	issued	the	following	exemptions

to	this	regulation	to	Exemptions	Nos.	10700,	8738,	10167	and	10167A.

14	C.F.R.	§	61.113	(a)	&	(b):	Private	Pilot	Privileges	and	Limitations:	Pilot	in	Command.

G5	 PICs	will	be	FAA	Private rated	pilots. Sections 61.113	(a)	&	(b)	limit	private	pilots	to	non-commercial	

operations. Because	the	UAS	will	not carry	a	pilot	or	passengers,	the	proposed	operations	can	achieve	the	

equivalent	level	of	safety	of current	operations	by	requiring	the	PIC	operating	the	aircraft	to	have	a	private

pilot’s	license	rather	than	a	commercial	pilot’s	license	to	operate	this	small	UAS.	Unlike	a

conventional	aircraft	that	carries	the	pilot	and	passengers,	the	UAS	is	remotely	controlled	with

no	living	thing	on	board.	The	area	of	operation	is	controlled	and	restricted,	and	all	flights	are

planned	and	coordinated	in	advance	as	set	forth	in	the	Manual.	The	level	of	safety	provided	by

the	requirements	included	in	the	Manual	exceeds	that	provided	by	a	single	individual	holding	a

Private pilot’s	certificate	operating	a	conventional	aircraft.	The	risks	associated	with	the

operation	of	the	UAS	are	so	diminished	from	the	level	of	risk	associated	with	commercial

operations	contemplated	by	Part	61	when	drafted,	that	allowing	operations	of	the	UAS	as

requested	with	a	private	pilot	as	the	PIC	exceeds	the	present	level	of safety	achieved	by	14

C.F.R.	§61.113	(a)	&	(b).
14	C.F.R.	§91.7(a):	Civil	aircraft	airworthiness.

The	regulation	requires	that	no	person	may	operate	a	civil	aircraft	unless	it	is	in

airworthy	condition.	As	there	will	be	no	airworthiness	certificate	issued	for	the	aircraft,	should

this	exemption	be	granted,	no	FAA	regulatory	standard	will	exist	for	determining	airworthiness.

Given	the	size	of	the	aircraft	and	the	requirements	contained	in	the	Manual	for	maintenance

and	use	of	safety	check	lists	prior	to	each	flight,	as	set	forth	in	Sections	J,	L	and	Q,	an	equivalent

level	of	safety	will	be	provided.

14	C.F.R.	§	91.9	(b)	(2):	Civil	Aircraft	Flight	Manual	in	the	Aircraft.

Section	91.9	(b)	(2)	provides:

No	person	may	operate	a	U.S.-registered	civil	aircraft	...

(2)	For	which	an	Airplane	or	Rotorcraft	Flight	Manual	is	not	required	by	§21.5	of

this	chapter,	unless	there	is	available	in	the	aircraft	a	current	approved	airplane	or

Rotorcraft	Flight	Manual,	approved	manual	material,	markings,	and	placards,	or	any

combination	thereof.

The	UAS,	given	its	size	and	configuration	has	no	ability	or	place	to	carry	such	a	flight

manual	on	the	aircraft,	not	only	because	there	is	no	pilot	on	board,	but	because	there	is	no

room	or	capacity	to	carry	such	an	item	on	the	aircraft.	The	equivalent	level	of	safety	will	be

maintained	by	keeping	the	flight	manual	at	the	ground	control	point	where	the	pilot	flying	the

UAS	will	have	immediate	access	to	it.	The	FAA	has	issued	the	following	exemptions	to	this

regulation:	Exemption	Nos.	8607,	8737,	8738,	9299,	9299A,	9565,	9565B,	10167,	10167A,	10602,

32827,	and	10700.

14	C.F.R.	§	91.103: Preflight	action

This	regulation	requires	each	pilot	in	command	to	take	certain	actions	before

flight	to	insure	the	safety	of	flight.	As	FAA	approved	rotorcraft	flight	manuals	will	not	be

provided	for	the	aircraft	an	exemption	will	be	needed.	An	equivalent	level	of	safety	will	be	set

forth	by	the	pre-flight	checklist	as	set	forth	in	the	Flight	Operations	Manual.	The	PIC	will	take all

actions	including	reviewing	weather,	flight	battery	requirements,	landing	and	takeoff	distances,

aircraft	performance	data	and	setting	the	pre-determined	safe	landing	area	in	case	of	loss	of

GPS	communication	before	initiation	of	flight.

14	C.F.R.	§91.109: Flight	instruction:

Section	91.103	provides	that	no	person	may	operate	a	civil	aircraft	(except	a	manned

free	balloon)	that	is	being	used	for	flight	instruction	unless	that	aircraft	has	fully	functioning	dual

controls.	UAS and	remotely	piloted	aircraft,	by	their	design	do	not	have	fully	functional	dual

controls.	Flight	control	is	accomplished	through	the	use	of	a	control	box	that	communicates

with	the	aircraft	via	radio	communications.	The	FAA	has	approved	exemptions	for	flight	training

without	fully	functional	dual	controls	for	a	number	of	aircraft	and	for	flight	instruction	in

experimental	aircraft.	See	Exemption	Nos.5778K	&	9862A.	The	equivalent	level	of	safety

provided	by	the	fact	that	neither	a	pilot	nor	passengers	will	be	carried	in

the	aircraft	and	by	the	size	and	speed	of	the	aircraft.

14	C.F.R.	§91.119:	Minimum	safe	altitudes

Section	91.119	establishes	safe	altitudes	for	operation	of	civil	aircraft.	Section	91.119	(d)

allows	helicopters	to	be	operated	at	less	than	the	minimums	prescribed,	provided	the	person

operating	the	helicopter	complies	with	any	route	or	altitudes	prescribed	for	helicopters	by	the

FAA.	As	this	exemption	is	for	a	sUAS	that	is	a	helicopter	and	the	exemption	requests	authority

to	operate	at	altitudes	up	to	400	AGL,	or	not more	than	200	above	an	elevated	platform	from

which	filming	is	planned,	an	exemption	may	be	needed	to	allow	such	operations.	The	sUAS	will
never	operate	at higher	than	400	AGL.	It	will	however	be	operated	in	a	restricted	area	with	security	

perimeter, where	buildings	and	people	will	not	be	exposed	to	operations	without	their	pre-obtained

consent.

The	equivalent	level	of	safety	will	be	achieved	given	the	size,	weight,	speed	of	the	UAS

as	well	as	the	location	where	it	is	operated.	No	flight	will	be	taken	without	the	permission	of

the	property	owner	or	local	officials.	Because	of	the	advance	notice	to	the	property	owner	and

participants	in	the	filming	activity,	all	affected	individuals	will	be	aware	of	the	planned	flight

operations.	Compared	to	flight	operations	with	aircraft	or	rotorcraft	weighting	far	more	than

the	maximum	lbs.	proposed	herein	and	the	lack	of	flammable	fuel,	any	risk	associated	with

these	operations	is	far	less	than	those	presently	presented	with	conventional	aircraft	operating

at	or	below	500	AGL	in	aerial	photography	and	cinematography	industry.	In	addition,	the	low altitude

operations	of	the	UAS	will	ensure	separation	between	these	UAS	operations	and	the

operations	of	conventional	aircraft	that	must	comply	with	Section	91.119.

14	C.F.R.	§91.121	Altimeter	Settings

This	regulation	requires	each	person	operating	an	aircraft	to	maintain	cruising	altitude	by

reference	to	an	altimeter	that	is	set	“...to	the	elevation	of	the	departure	airport	or	an

appropriate	altimeter	setting	available	before	departure.”	As	the	sUAS	may	not	have	a

barometric	altimeter,	but	instead	a	GPS	altitude	read	out,	an	exemption	may	be	needed.	An

equivalent	level	of	safety	will	be	achieved	by	the	operator,	pursuant	to	the	Pre	Flight	Check	list,

confirming	the	altitude	of	the	launch	site	shown	on	the	GPS	altitude	indicator	before	flight.

14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions

Section	91.151	(a)	prohibits	an	individual	from	beginning	“a	flight	in	an	airplane	under

VFR	conditions	unless	(considering	wind	and	forecast	weather	conditions)	there	is	enough	fuel

to	fly	to	the	first	point	of	intended	landing,	and,	assuming	normal	cruising	speed	– (1)	During	the

day,	to	fly	after	that	for	at	least	30	minutes;	or	(2)	At	night,	to	fly	after	that	for	at	least	45

minutes.”

The	battery	powering	the	UAS	provides	approximately	25 minutes	of	powered	flight.	To

meet	the	30	minute	reserve	requirement	in	14	CFR	§91.151,	UAS	flights	would	be	limited	to

approximately	10	minutes	in	length.	Given	the	limitations	on the	UAS’s	proposed	flight	area	and

the	location	of	its	proposed	operations	within	a	predetermined	area,	a	longer	time	frame	for

flight	in	daylight	or	night	VFR	conditions	is	reasonable.

G5 Drones	believes	that	an	exemption	from	14	CFR	§91.151(a)	falls	within	the	scope

of	prior	exemptions.	See	Exemption	10673	(allowing	Lockheed	Martin	Corporation	to	operate

without	compliance	with	FAR	91.151	(a)).	Operating	the	small	UAS,	in	a	tightly	controlled	area

where	only	people	and	property	owners	or	official	representatives	who	have	signed	waivers	will

be	allowed,	with	less	than	30	minutes	of	reserve	fuel,	does	not	engender	the	type	of	risks	that

Section	91.151(a)	was	intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS.

Additionally,	limiting	UAS	flights	to	10	minutes	would	greatly	reduce	the	utility	for	which	the

exemption	will	be	granted.

Applicant	believes	that	an	equivalent	level	of	safety	can	be	achieved	by	limiting	flights	to

25 minutes	or	25%	of	battery	power	whichever	happens	first.	This	restriction	would	be	more

than	adequate	to	return	the	UAS	to	its	planned	landing	zone	from	anywhere	in	its	limited

operating	area.

Similar	exemptions	have	been	granted	to	other	operations,	including	Exemptions	2689F,

5745,	10673,	and	10808.
14	C.F.R.	§91.203	(a)	and	(b):	Carrying	Civil	Aircraft	Certification	and	Registration

The	regulation	provides	in	pertinent	part:

(a)	Except	as	provided	in	§	91.715,	no	person	may	operate	a	civil	aircraft	unless	it

has	within	it	the	following:

(1)	An	appropriate	and	current	airworthiness	certificate.	.	.	.

(b)	No	person	may	operate	a	civil	aircraft	unless	the	airworthiness	certificate

required	by	paragraph	(a)	of	this	section	or	a	special	flight	authorization	issued

under	§91.715	is	displayed	at	the	cabin	or	cockpit	entrance	so	that	it	is	legible	to

passengers	or	crew.

The	UAS	fully	loaded	weighs	no	more	than	55	lbs	and	is	operated	without	an	onboard

pilot.	As	such,	there	is	no	ability	or	place	to	carry	certification	and	registration	documents	or	to

display	them on	the	UAS.

An	equivalent	level	of	safety	will	be	achieved	by	keeping	these	documents	at	the	ground

control	point	where	the	pilot	flying	the	UAS	will	have	immediate	access	to	them,	to	the	extent

they	are	applicable	to	the	UAS.	The	FAA	has	issued	numerous exemptions	to	this	regulation.

A	representative	sample	of	other	exceptions	includes	Exemption	Nos.	9565,	9665,	9789,	9789A,

9797,	9797A,	9816A,	and	10700.

14	C.F.R.	§91.405	(a);	407	(a)	(1);	409	(a)	(2);	417(a)	&	(b):	Maintenance	Inspections

These	regulations	require	that	an	aircraft	operator	or	owner	“shall	have	that	aircraft

inspected	as	prescribed	in	subpart	E	of	this	part	and	shall	between	required	inspections,	except

as	provided	in	paragraph	(c)	of	this	section,	have	discrepancies	repaired	as	prescribed	in	part	43

of	this	chapter...,”	and	others	shall	inspect	or	maintain	the	aircraft	in	compliance	with	Part	43.

Given	that	these	section	and	Part	43	apply	only	to	aircraft	with	an	airworthiness

certificate,	these	sections	will	not	apply	to	the	applicant.	Maintenance	will	be	accomplished	by

the	operator	pursuant	to	the	flight	manual	and	operating	handbook.	An	equivalent	level	of

safety	will	be	achieved	because	these	small	UASs	are	very	limited	in	size	and	will	carry	a	small

payload	and	operate	only	in	restricted	areas	for	limited	periods	of	time.	If	mechanical	issues

arise	the	UAS	can	land	immediately	and	will	be	operating	from	no	higher	than	400	feet	AGL.	The

operator	will	ensure	that	the	UAS	is	in	working	order	prior	to	initiating	flight,	perform	required

maintenance,	and	keep	a	log	of	any	maintenance	performed.	Moreover,	the	operator	is	the

person	most	familiar	with	the	aircraft	and	best	suited	to	maintain	the	aircraft	in	an	airworthy

condition	to	provide	the	equivalent	level	of	safety.

Pursuant	to	14	C.F.R.	Part	11,	the	following	summary	is	provided	for	publication	in	the

Federal	Register,	should	it	be	determined	that	publication	is	needed:

Applicant	seeks	an	exemption	from	the	following	rules:

14	C.F.R.	§21,	subpart	H;	14	C.F.R	45.23(b);14	C.F.R.	§§	61.113(	a)	&	(b);91.7	(a);

91.9	(b)	(2);91.103(b);91.109;	91.119;	91.121;	91.151(a);91.203(a)	and	(b);	91.405

(a);	91.407	(a)	(1);	91.409	(a)	(2);	91.409	(a)	(2)	and	91.417	(a)	&	(b)	to	operate

commercially	a	small	unmanned	vehicle	(55lbs	or	less)	in	aerial	photography	and

cinematography	for	residential	and	commercial	real	estate	and	closed-set	special

events.

Approval	of	exemptions	allowing	commercial	operations	of	UAS	for	aerial photography	and

cinematography	for	real	estate	and	close-set	special	events will	enhance	safety by	reducing

risk.	Conventional	real	estate	aerial	photography	and	cinematography	use	jet	or

piston	powered	aircraft	which	carry	large	amounts	of	combustible fuel	posing	increased	risk.

Conversely,	UAS	carry	no	combustible fuel,	weigh	only	55	lbs.	or	less	comparatively	to	3,000+

lbs.	of	a	conventional	aircraft,	are	much	more	easily	maneuverable	and	do	not	ferry	to	and	from

the	production	location.	Additionally,	flying	at	or	below	400	AGL	UAS	will	be	no	factor	with
fixed	wing	and	rotor	wing	aircraft.

The	operation	of	small	UASs,	weighting	less	than	55	lbs.,	conducted	in	the	strict

conditions	outlined	above,	will	provide	an	equivalent	level	of	safety	supporting	the	grant	of	the

exemptions	requested	herein,	including	exempting	the	applicant	from	the	requirements	of	Part

21	and	allowing	commercial	operations.	These	lightweight	aircraft	operate	at	slow	speeds,	close

to	the	ground,	and	in	a	sterile	environment	and,	as	a	result,	are	far	safer	than	conventional

operations	conducted	with	traditional	aircraft	which	pose	a	safety	risk.	There	are	no	personnel

on	board	the	UAS	and	therefore	the	likelihood	of	death	or	serious	bodily	injury	is	significantly

diminished.	All	flights	will	occur	over	private	or	controlled	access	property	with	the	property

owner’s	prior	consent	and	knowledge.	Filming	will	be	of	people	who	have	also	consented	to

being	filmed	or	otherwise	have	agreed	to	be	in	the	area	where	filming	will	take	place.	SMG

Drones	will	provide	an	equivalent	or	better	level	of	safety	as	that	achieved under	the	current

FAR’s.

G5 Drones	respectfully	request	that	the	FAA	grants	the	exemption	request.

Satisfaction	of	the	criteria	provided	in	Section	333	of	the	Reform	Act	of	2012--size,	weight,

speed,	operating	capabilities,	proximity	to	airports	and	populated	areas	and	operation	within

visual	line	of	sight	and	national	security	– provide	more	than	adequate	justification	for	the	grant

of	the	requested	exemptions	allowing	commercial	operation	of	applicant’s	UAS	in	aerial

photography	and	cinematography	for	the	real	estate	industry	and	close-set	special	events

pursuant	to	the	Manuals	appended	hereto.